ML15069A231

Millstone, Unit 2 - Six-Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)

ML15069A231
Person / Time
Site:	Millstone
Issue date:	03/02/2015
From:	Sartain M D Dominion, Dominion Nuclear Connecticut
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
14-393B, EA-12-049
Download: ML15069A231 (26)

Text

Dominion Nuclear Connecticut, Inc. A D *

• 5000 Dominion Boulevard, Glen Allen, VA 23060 Dominion Web Address: www.dom.com March 2, 2015 10 CFR 2.202 EA-12-049 Attention:

Document Control Desk Serial No.: 14-393B U.S. Nuclear Regulatory Commission NL&OS/MAE:

R4 Washington, D.C. 20555-0001 Docket No.: 50-336 License No.: DPR-65 DOMINION NUCLEAR CONNECTICUT, INC.MILLSTONE POWER STATION UNIT 2 SIX-MONTH STATUS REPORT IN RESPONSE TO MARCH 12, 2012 COMMISSION ORDER MODIFYING LICENSES WITH REGARD TO REQUIREMENTS FOR MITIGATION STRATEGIES FOR BEYOND-DESIGN-BASIS EXTERNAL EVENTS (ORDER NUMBER EA-12-049)

References:

1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012 2. Dominion Nuclear Connecticut, Inc., Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (Serial No. 12-1611B)3. Dominion Nuclear Connecticut, Inc., Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2014 (Serial No.14-393)On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an order (Reference

1) to Dominion Nuclear Connecticut, Inc. (DNC). Reference 1 was immediately effective and directed DNC to develop, implement, and maintain guidance and strategies to maintain core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event.Reference I required submission of an Overall Integrated Plan (OIP) (Reference 2)pursuant to Section IV, Condition C. Reference 1 also required submission of a status report at six-month intervals following submittal of the OIP.Attachment 1 to this letter provides the fourth six-month status report and an update of milestone accomplishments since the submittal of the previous six-month status report Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Page 2 of 3 (Reference 3), including any changes to the compliance method, schedule, or need for relief and the basis.If you have any questions, please contact Ms. Margaret Earle at (804) 273-2768.Sincerely, Mark D. Sartain Vice President

-Nuclear Engineering Attachments (2)Commitments made by this letter: No new Regulatory Commitments COMMONWEALTH OF VIRGINIA)COUNTY OF HENRICO The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Mark D. Sartain who is Vice President

-Nuclear Engineering of Dominion Nuclear Connecticut, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of the Company, and that the statements in the document are true to the best of his knowledge and belief.Acknowledged before me this ,,.....day of MaVrck' 2015.My Commission Expires: Lre..t 4 er 310,,/W.I Notary Public N Commonwealth of Virginia (SEAL) Reg. # 7518653 (SEAL) IMy Commission Expires December 31, 2O.ei a Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Page 3 of 3 cc: Director of Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 13H16M 11555 Rockville Pike Rockville, MD 20852-2738 U. S. Nuclear Regulatory Commission, Region I Regional Administrator 2100 Renaissance Blvd.Suite 100 King of Prussia, PA 19406-2713 Mr. M. C. Thadani NRC Senior Project Manager Millstone Units 2 and 3 U. S. Nuclear Regulatory Commission One White Flint North Mail Stop 08 B1 11555 Rockville Pike Rockville, MD 20852-2738 NRC Senior Resident Inspector Millstone Power Station Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Six-Month Status Report for the Implementation of Order EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events February 2015 Millstone Power Station Unit 2 Dominion Nuclear Connecticut, Inc. (DNC)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 1 of 22 Six-Month Status Report for the Implementation of Order EA-1 2-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events 1 Introduction Dominion Nuclear Connecticut, Inc. (DNC) developed an Overall Integrated Plan (OIP)(Reference 1), documenting the diverse and flexible strategies (FLEX) for Millstone Power Station Unit 2 (MPS2), in response to NRC Order Number EA-12-049 (Reference 2). This attachment provides an update of milestone accomplishments and open items since the last status report (Reference 3), including changes to the compliance method, schedule, or need for relief/relaxation and the basis, if any.2 Milestone Accomplishments The following milestones have been completed since the development of the OIP, and are current as of January 31, 2015." Submit Integrated Plan" Develop Strategies" Develop Training Plan* Develop Strategies/Contract with NSRC* Purchase Equipment" Receive Equipment* Create Maintenance Procedures 3 Milestone Schedule Status The following table provides an update to Attachment 2A of the OIP. It provides the activity status of each item as of January 31, 2015, and whether the expected completion date has changed. The dates are planning dates subject to change as design and implementation details are developed.

The revised milestone target completion dates for 'Develop Modifications,'

'Implement Modifications,'

'Implement Training,'

'Issue FSGs and Associated Procedure Revisions,'

'Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures,'

and'Outage Implementation' do not impact the Order implementation date.

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment I Page 2 of 22 Target Revised Milestone Completion Activity Status Target Date Completion Date Submit Integrated Plan February 2013 Complete Develop Strategies April 2014 Complete Develop Modifications December 2014 Started March 2015*Implement Modifications October 2015 Started Develop Training Plan April 2014 Complete Implement Training April 2015 Started September 2015*Issue FSGs and Associated July 2015 Started September Procedure Revisions July_2015 Started 2015*Develop Strategies/Contract with August 2014 Complete NSRC**Purchase Equipment February 2014 Complete Receive Equipment September 2014 Complete Validation Walk-throughs or Demonstrations of FLEX December 2014 Started February 2015*Strategies and Procedures Create Maintenance August 2014 Complete Procedures*

August_2014 Complete Outage Implementation October 2015 Not Started* Refer to Section 8, Supplemental Information, for an explanation of the change to this Milestone.

• • NSRC is the National SAFER Response Center.4 Changes to Compliance Method By letter dated February 28, 2013, (Reference 1), DNC provided an OIP to address Beyond-Design-Basis (BDB) events at MPS2 and MPS Unit 3 (MPS3) as required by Order Number EA-12-049, dated March 12, 2012. The first Six-Month Status Update of the OIP for MPS2 and MPS3 was provided by letter dated August 23, 2013 (Reference 4). The second and third Six-Month Status Updates for MPS2 were provided by letters dated February 28, 2014 (Reference

3) and August 28, 2014 (Reference 5), respectively.

Listed below are changes to the compliance method information provided in the MPS2 OIP and subsequent updates. These changes continue to meet Nuclear Energy Institute (NEI) 12-06 guidance (Reference 6):

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 3 of 22 a. An alternate location for the 120 VAC and 480 VAC Diesel Generators (DGs) has been identified in the event that the "Courtyard" area at the west end of the MPS Unit 1 (MPS1) Radwaste Building is not accessible.

The alternate area for the 480 VAC DG is in the alleyway just south of the MPS1 Radwaste Building.

The alternate area for the 120/240 VAC DG is in the area east of the MPS2 Auxiliary Building at the Health Physics entrance.

The available cables for both DGs are of sufficient length for either their primary or alternate locations.

The alternate areas were identified in response to concerns for blockage of the haul route to the primary"courtyard" location due to failure of the MPS stack structure.

The tie-in location for the NSRC High Capacity / Low Pressure pump that is used to supply cooling water from Long Island Sound for either the primary or the alternate Containment cooling strategy was incorrectly identified in OIP Figures 10 and 11 provided in the February 2014 Six Month Status Update (Reference 3). These figures have been revised and included at the end of this attachment.

5 Need for Relief/Relaxation and Basis for the Relief/Relaxation DNC expects to comply with the order implementation date and no relief/relaxation is required at this time.6 Open Items The Nuclear Regulatory Commission (NRC) has established an audit process to allow the exchange of information between the licensees and the NRC Staff (Reference 7).Between July 21, 2014 and July 25, 2014, MPS2 and MPS3 were the subject of an NRC onsite audit where the site specific aspects of DNC's proposed FLEX Mitigating Strategies were reviewed.

During this NRC onsite audit, the staff reviewed site specific documentation and upon completion of the audit, indicated that further review of several items was not anticipated as DNC proceeds towards compliance for Orders EA-12-049 and EA-12-051.

These items are identified in the following tables in Section 6. Note that the tables provided in Sections 6.4 and 6.5 are new and are the result of the ongoing NRC audit process.6.1. Open Items from Overall Integrated Plan The following table provides a summary of the status of Open Items (01) identified by DNC and documented in Attachment 2B of the MPS2 OIP submitted on February 28, 2013 and the status of each item.

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 4 of 22 Overall Integrated Plan Open Items 01 # Description Status Verify response times listed in See Milestone Schedule above for completion timeline and perform staffing schedule.assessment.

In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference 8)Preliminary analyses have been Complete. (Reference 9)performed to determine the time to steam generator (SG) overfill In the Final Audit Report from the July 2014 without operator action to reduce NRC Onsite Audit, the NRC Staff indicated that 2 Auxiliary Feedwater (AFW) flow, further review of this item was not anticipated as time to SG dryout without AFW DNC proceeds towards compliance for Order flow, and time to depletion of the EA-12-049. (Reference 8)Condensate Storage Tank (CST).Final durations will be provided when the analyses are completed.

Analyses will be performed to Complete.develop fluid components performance requirements and The hydraulic calculations for the FLEX pumps confirm fluid hydraulic-related deployed using their associated hose networks strategy objectives can be met. have confirmed that the primary and the alternate connections for core cooling/decay heat removal, RCS Inventory, and reactivity control (RCS Injection), and Spent Fuel Pool (SFP) make-up strategies can be satisfactorily accomplished in response to an extended loss of alternating current (ac) power (ELAP)/Loss of 3 Ultimate Heat Sink (LUHS) event. (Reference 10)Hydraulic calculations have confirmed that the service water (SW) flows for the Containment cooling options are adequate. (Reference 10)In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference

8)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 5 of 22 Overall Intearated Plan Onen Items 01 # Description Status A study is in progress to determine Complete.the design features, site location(s), and number of A single 10,000 sq. ft. Type 1 building has been equipment storage facilities.

The constructed at MPS for storage of BDB final design for BDB equipment equipment.

The building is designed to meet storage will be based on the the plant's design basis for the Safe Shutdown guidance contained in NEI 12-06, Earthquake, high wind hazards, snow, ice and Section 11.3, Equipment Storage. cold conditions, and is located above the flood 4 A supplement to this submittal will elevation from the most recent site flood be provided with the results of the analysis.equipment storage study.The BDB Storage Building is sited south of the railroad bridge, on the west side of the MPS access road, adjacent to the existing northeast contractor parking lot. (References 11 and 12)FLEX Support Guidelines (FSGs) Started.will be developed in accordance 5 with PWROG guidance.

Existing Scheduled completion date is revised from July procedures will be revised as 2015 to September 2015*necessary to implement FSGs.Electric Power Research Institute Complete.(EPRI) guidance documents will be used to develop periodic testing EPRI guidance documents have been used, and preventative maintenance where available, to develop the testing and procedures for BDB equipment.

preventative maintenance strategies for the Procedures will be developed to sites. Fleet-wide templates have been manage unavailability of developed and input into the individual site equipment such that risk to maintenance strategies.

Specific Preventative mitigating strategy capability is Maintenance (PM) procedures based on these minimized, strategies will be implemented prior to the 6 required MPS2 compliance date for Order EA-12-049.A fleet-wide FLEX Strategy Program Document has been developed (Refer to Open Item 7).The program includes the requirement to manage unavailability of equipment such that risk to mitigating strategy capability is minimized.

A fleet-wide procedure has been developed to specifically address equipment unavailability. (Reference

13)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 6 of 22 Overall Intearated Plan Onen Items 01 # Description Status In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference 8)An overall program document will Complete.be developed to maintain the FLEX strategies and their bases, In the Final Audit Report from the July 2014 7 and provide configuration control NRC Onsite Audit, the NRC Staff indicated that and change management for the further review of this item was not anticipated as FLEX Program. DNC proceeds towards compliance for Order EA-12-049. (Reference 8)The DNC Nuclear Training Complete.Program will be revised to assure personnel proficiency in the In the Final Audit Report from the July 2014 mitigation of BDB events is NRC Onsite Audit, the NRC Staff indicated that developed and maintained.

These further review of this item was not anticipated as 8 programs and controls will be DNC proceeds towards compliance for Order developed and implemented in EA-12-049. (Reference 8)accordance with the Systematic Approach to Training (SAT).Complete.The Combustion Engineering (CE) Owners Group has issued generic guidelines to address plant response for post-loss of all AC power for CE plants. Based on these guidelines, DNC has developed plant specific FSGs for MPS2 to Confirm consistency of the FLEX address plant response for post-loss of all AC strategies with the PWROG power. Specifically, MPS2 will depressurize the 9 evaluation of post-loss of all AC steam generators (SGs) to a plant specific power plant response for target SG pressure to prevent Safety Injection Combustion Engineering plants. Tank (SIT) nitrogen injection. (Reference 14)In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference

8)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 7 of 22 Overall Intearated Plan Open Items 01 # Description Status Develop strategy for use of the Complete.BDB AFW Pump to provide SG injection in the unlikely event of A modification to the storm preparation loss of TDAFW pump due to procedure has been developed which requires hurricane related storm surge the early deployment of one BDB auxiliary flooding of the Turbine Building.

feedwater (AFW) pump to the MPS2 Turbine Building Truck Bay. The modification will go into 10 effect upon implementation of the MPS2 FSGs.(Reference 12)In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference 8)Plant modifications will be See Milestone Schedule above for completion completed for permanent plant schedule.changes required for implementation of FLEX In the Final Audit Report from the July 2014 11 strategies.

NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference 8)Complete.The evaluation identified the need for a plant modification to the ADV outlet lines. The identified modification is included in Open Item Complete the engineering 11.12 evaluation of the main steam (MS) (Reference 15)atmospheric dump valve (ADV)outlet lines. In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference

8)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 8 of 22 Overall Integrated Plan Open Items 01 # Description Status Complete.Complete the evaluation of Turbine driven auxiliary feedwater (TDAFW)TDAFW pump long term operation pump operation and adequate AFW flow to the with < 120 psig inlet steam SGs at SG pressures

< 120 psig has been pressure.

confirmed. (References 15 and 16)The Phase 3 coping strategy to Complete.maintain Containment integrity is under development.

Methods to In the Final Audit Report from the July 2014 14 monitor and evaluate Containment NRC Onsite Audit, the NRC Staff indicated that conditions and depressurize/cool further review of this item was not anticipated as Containment, if necessary, will be DNC proceeds towards compliance for Order provided in a future update. EA-12-049. (Reference 8)Analyses will be performed to Complete.develop electrical components performance requirements and Calculations have been completed for the sizing confirm electrical loading-related and loading analysis of the 120VAC, 480VAC, strategy objectives can be met. and 4160 VAC generators and confirm the electrical loading-related strategy objectives can be met (Reference 17).15 In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference 8)Complete.An evaluation of the BDB equipment fuel consumption and required refill strategies has been completed and provided as part of the An evaluation of all BDB ongoing NRC audit process.16 equipment fuel consumption and (Reference 12)required re-fill strategies will be developed.

In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference

8)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 9 of 22 Overall Integrated Plan Open Items 01 # Description Status A lighting study will be performed Complete.to validate the adequacy of supplemental lighting and the A lighting study has been completed validating adequacy and practicality of using the adequacy of supplemental lighting and the portable lighting to perform FLEX adequacy and practicality of using portable strategy actions. lighting to perform FLEX Strategy actions. This was provided as part of the ongoing NRC audit 17 process.(Reference 12)In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference 8)A comprehensive study of Complete.communication capabilities is being performed in accordance A study documenting the communications with the commitments made in strategy has been completed.

The study DNC letter S/N 12-205F dated concludes that effective implementation of the October 29, 2012 in response to FLEX strategies will include the use of satellite Recommendation 9.3 of the 10 phones and hand-held radios. The study CFR 50.54(f) letter dated March acknowledges that MPS2 does not have a 12, 2012. The results of this study sound-powered phone system or equivalent will identify the communication and that radio usage has limitations in a few means available or needed to remote plant locations.

These remote implement command and control locations are, however, associated only with 18 of the FLEX strategies at alternate BDB connections. (Reference 18).Millstone.

Validation of The tabletop assessment of the FLEX communications required to strategies performed as part of the Phase 2 implement FLEX strategies will be Staffing study has identified that the performed as part of Open Item coordination of command and control of the No. 1. FLEX strategies will require the use of dispatched personnel.

In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference

8)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 10 of 22 Overall Integrated Plan Open Items 01 # Description Status Details of the ventilation strategy Complete.are under development and will conform to the guidance given in See Attachment 2, OIP Section F5 -Safety NEI 12-06. The details of this Functions Support (Ventilation).

strategy will be provided at a later 19 date. In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference 8)Preferred travel pathways will be Complete.determined using the guidance contained in NEI 12-06. The The soil liquefaction study has been completed pathways will attempt to avoid (Reference 19), which supports the location of areas with trees, power lines, and the storage building and the haul routes. The other potential obstructions and results have been included with the final design will consider the potential for soil package for the storage building (Reference 20 liquefaction.

11).In the Final Audit Report from the July 2014 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference 8)The equipment listed in Table 1 Complete.will be received on site.In the Final Audit Report from the July 2014 21 NRC Onsite Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049. (Reference

8)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 11 of 22 6.2. Open Items from Interim Staff Evaluation (ISE)The following table provides a summary of the Open Items (01) from the MPS2 ISE (Reference

20) and the status of each item.Interim Staff Evaluation Open Items 01 # Description Status 3.2.1.8.A Core Subcriticality and Boron Mixing: The Complete.PWROG submitted to NRC a position paper, dated August 15, 2013, which provides test In the Final Audit Report from data regarding boric acid mixing under single- the July 2014 NRC Onsite phase natural circulation conditions and Audit, the NRC Staff indicated outlined applicability conditions intended to that further review of this item ensure that boric acid addition and mixing was not anticipated as DNC would occur under conditions similar to those proceeds towards compliance for which boric acid mixing data is available, for Order EA-12-049.(Reference 8)During the audit process, the licensee informed the NRC staff of its intent to abide by the generic approach discussed above.The licensee should address the clarifications in the NRC endorsement letter dated January 8, 2014.3.2.4.1.A The licensee did not provide sufficient This ISE 01 has been information regarding cooling functions addressed as follows: provided by such systems as auxiliary building cooling water, service water, or Permanently installed plant component cooling water cooling when ac equipment used to support power is lost during the ELAP for Phase 1 FLEX strategies does not and 2. For example, the potential need for require cooling support cooling water for the TDAFW pump bearings systems, such as component was not discussed.

Additional analysis by thE cooling water and service licensee is required to determine the water, to perform their required acceptability of the licensee's plans to provide functions.

Therefore, no supplemental cooling to the subject additional analysis is required components when normal cooling will not be to confirm the acceptability of available during the ELAP. supplemental cooling to plant equipment supporting Phase 1 or 2 strategies.(Reference 12)This ISE Confirmatory Item (CI is being addressed through the ongoing NRC audit process.

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 12 of 22 Interim Staff Evaluation Open Items 01 # Description Status (Reference 7)6.3. Confirmatory Items from Interim Staff Evaluation The following table provides a summary of the Confirmatory Items (CI) from the MPS2 ISE and the status of each item.Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.1.1.2.A Confirm that the preferred travel pathways This ISE Cl is being addressed are determined using the guidance contained through the ongoing NRC audit in NEI 12-06. The pathways will attempt to process.avoid areas with trees, power lines, and other (References 12 and 7)potential obstructions and will consider the potential for soil liquefaction.

This is scheduled to be completed in June 2014.3.1.1.3.A Confirm that a review is completed to In the Final Audit Report from determine impacts from large internal floodin, the July 2014 NRC Onsite sources that are not seismically robust and Audit, the NRC Staff indicated do not require ac power. that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049.(Reference 8)3.1.1.4.A The licensee's plan for implementing the use This ISE Cl is being addressed of off-site resources is not complete.

The through the ongoing NRC audit local assembly areas have not been process.identified.

The licensee is also evaluating the (References 12 and 7)possibility of boat transport for personnel.

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 13 of 22 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.1.2.2.A The licensee has identified open items In the Final Audit Report from related to deployment of equipment during the July 2014 NRC Onsite flooding conditions resulting from a hurricane; Audit, the NRC Staff indicated to verify response times listed in the timeline that further review of this item and perform staffing assessment, and to was not anticipated as DNC perform an evaluation of all BDB equipment proceeds towards compliance fuel consumption and required re-fill for Order EA-12-049.

strategies, and to determine preferred travel (Reference 8)pathways using the guidance contained in NEI 12- 06. The pathways will attempt to avoid areas with trees, power lines, and other potential obstructions.

3.2.1.A Confirm that Combustion Engineering Case In the Final Audit Report from 21 in WCAP-17601-P, as evaluated in MPS2 the July 2014 NRC Onsite document ETE-NAF-2012-0150, Section 6.1, Audit, the NRC Staff indicated is representative for MPS2 and appropriate that further review of this item for simulating the ELAP transient.

was not anticipated as DNC proceeds towards compliance for Order EA-1 2-049.(Reference 8)3.2.1.1.A Confirm that Westinghouse letter LTR-TDA- In the Final Audit Report from 13-31, Rev. 0-B, Attachment 1, shows that the July 2014 NRC Onsite the CENTS code used in the ELAP analysis Audit, the NRC Staff indicated for Combustion Engineering (CE) plants is that further review of this item limited to analyzing the flow conditions before was not anticipated as DNC reflux boiling initiates.

This review should proceeds towards compliance confirm an acceptable definition for the for Order EA-12-049.

initiation of reflux boiling. (Reference 8)3.2.1.2.A The RCP seal initial maximum leakage rate In the Final Audit Report from should be greater than or equal to the upper the July 2014 NRC Onsite bound expectation for the seal leakage rate Audit, the NRC Staff indicated for the ELAP event discussed in the PWROG that further review of this item position paper addressing the RCP seal was not anticipated as DNC leakage for CE plants (ADAMS Accession proceeds towards compliance No. ML13235A151 (Non-Publicly Available))

for Order EA-12-049.

or justification should be provided for use of a (Reference 8)lower value.

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 14 of 22 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.2.1.6.A Sequence of Event (SOE) action Item 5 In the Final Audit Report from indicates that the ELAP is declared at 45 the July 2014 NRC Onsite minutes, and Action Item 6 indicates that at Audit, the NRC Staff indicated 50 minutes (5 minutes after the declaration of that further review of this item the ELAP), the operator controls SG was not anticipated as DNIC atmospheric dump valves (ADVs) and AFW proceeds towards compliance flow locally as an on-going action for for Order EA-12-049.

cooldown and decay heat removal. On page (Reference 8)105 of the integrated plan in Attachment 1B NSSS Significant Reference Analysis Deviation Table, the licensee notes in item 6 that cooldown starts at 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 75 degrees F/hr. to a SG pressure of 135 psia.Clarification is needed to correct this apparent inconsistency.

3.2.1.6.B The licensee did not provide a discussion In the Final Audit Report from regarding the operator actions required to the July 2014 NRC Onsite control SG ADVs and AFW flow and Audit, the NRC Staff indicated justification is needed to determine that all that further review of this item the required operator actions are reasonably was not anticipated as DNC achievable within the required time constraint proceeds towards compliance of 50 minutes during the ELAP conditions, or for Order EA-1 2-049.a discussion regarding the required cooldown (Reference 8)completion time that is supportable by analysis.3.2.1.6. C Confirm that response times listed in the SOE In the Final Audit Report from timeline are verified and that staffing the July 2014 NRC Onsite assessment has been performed.

Audit, the NRC Staff indicated that further review of this item was not anticipated as DNIC proceeds towards compliance for Order EA-1 2-049.(Reference

8)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 15 of 22 Interim Staff Evaluation Confirmatory Items CI # Description Status 3.2.2.A Following a BDB event, a vent pathway would In the Final Audit Report from be required in the event of SFP bulk boiling the July 2014 NRC Onsite and can be established by opening the Fuel Audit, the NRC Staff indicated Building roll-up doors for inlet and outlet air that further review of this item flow. However the licensee's strategy for was not anticipated as DNC providing air flow to remove steam generated proceeds towards compliance from pool boiling is not clear. The path for for Order EA-1 2-049.inlet and exhaust air is apparently the same (Reference 8)i.e., the fuel building rollup doors. It is not clear from the discussion provided how this will enable a flow path to vent the steam and condensate from the Fuel Building.3.2.3.A During the audit process the licensee stated In the Final Audit Report from that the details of the long term Containment the July 2014 NRC Onsite cooldown and depressurization strategies for Audit, the NRC Staff indicated MPS2 are still under development.

Upon that further review of this item selection of the preferred strategy, detailed was not anticipated as DNC GOTHIC analysis will be performed to proceeds towards compliance document and validate the strategy and also to for Order EA-1 2-049.provide operators with timelines and guidelines (Reference 8)for actions to ensure the long term integrity of the Containment throughout the Phase 3 of the postulated ELAP/LUHS scenario.

Confirm that the revised analyses and the selected strategy are acceptable.

3.2.4.2.A The ventilation evaluation will be completed In the Final Audit Report from later this year and the results will be provided the July 2014 NRC Onsite in the February 2014 6-Month update. Confirm Audit, the NRC Staff indicated that the evaluation and results are acceptable.

that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049.(Reference 8)3.2.4.4.A Confirm the adequacy of existing lighting and In the Final Audit Report from the adequacy of portable lighting to perform the July 2014 NRC Onsite FLEX strategy actions. Audit, the NRC Staff indicated that further review of this item was not anticipated as DNC proceeds towards compliance for Order EA-12-049.(Reference

8)

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 16 of 22 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.2.4.4.B Confirm that upgrades to the site's This ISE Cl is being addressed communications systems have been through the ongoing NRC audit completed.

process. (Reference 7)3.2.4.6.A Additional information is needed to confirm This ISE Cl is being addressed habitability of the Main Control Room during through the ongoing NRC audit the ELAP. process. (Reference 7)3.2.4.7.A Westinghouse is currently performing an In the Final Audit Report from analysis to determine the consequences of the July 2014 NRC Onsite usage of impure water sources in the steam Audit, the NRC Staff indicated generators.

The results of the analysis are that further review of this item expected to provide the allowed time limits on was not anticipated as DNC usage of these sources. The NSRC will proceeds towards compliance provide equipment to initiate residual heat for Order EA-1 2-049.removal and water treatment equipment such (Reference 8)that heat removal can be ensured for extended durations.

Confirm that the analysis results and resultant strategies are acceptable.

3.2.4.9.A A secondary source for fuel oil will be the In the Final Audit Report from MPS3 Diesel Fuel Oil Storage Tanks. These the July 2014 NRC Onsite underground tanks contain a minimum of Audit, the NRC Staff indicated 32,670 gallons of fuel oil. They are seismic that further review of this item and missile protected.

Confirm the ability to was not anticipated as DNC transfer this fuel, and complete an evaluation o proceeds towards compliance all BDB equipment fuel consumption and for Order EA-1 2-049.required re-fill strategies, including any (Reference 8)gasoline required for small miscellaneous equipment.

3.2.4.10.A The licensee has completed an analysis of the This ISE Cl is being addressed battery capability regarding expected time through the ongoing NRC audit available with ac power. Site specific process. (Reference 7)procedural guidance governing load stripping will be developed.

Confirm electrical components performance requirements and electrical loading-related strategy objectives can be met.

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 17 of 22 Interim Staff Evaluation Confirmatory Items Cl # Description Status 3.4.A The licensee's plans for the use of off-site In the Final Audit Report from resources conform to the minimum capabilities the July 2014 NRC Onsite specified in NEI12-06 Section 12.2, with regard Audit, the NRC Staff indicated to the capability to obtain equipment and that further review of this item commodities to sustain and backup the site's was not anticipated as DNC coping strategies (item 1). Confirm the proceeds towards compliance licensee addresses the remaining items (2 for Order EA-12-049.

through 10), or provides an appropriate (Reference 8)alternative.

6.4. Audit

Questions Reviewed During the MPS2 NRC Onsite Audit Various MPS2 Audit Questions (AQs) were evaluated during the MPS NRC Onsite Audit.In the Final Audit Report from the July 2014 NRC Onsite Audit (Reference 8), the NRC Staff indicated that for the majority of the AQs items, further review was not anticipated as DNC proceeds towards compliance for Order EA-12-049.

However, the following AQs are still under review by the NRC Staff: AQ #s: 1, 2, 3, 6, 7, 8, 9, 12, 20, 32, 33, 35, 44, 58, 64, and 80 The responses to the above AQs are being addressed through the ongoing NRC audit process (Reference 7).6.5. Additional Items Reviewed During the MPS2 NRC Onsite Audit Additional Safety Evaluation (SE) Review items were identified and evaluated during the MPS NRC Onsite Audit.In the Final Audit Report from the July 2014 NRC Onsite Audit (Reference 8), the NRC Staff indicated that for the majority of these SE items, further review was not anticipated as DNC proceeds towards compliance for Order EA-12-049.

However, the following SEs are still under review by the NRC Staff: SE #s: 7, 8, and 9 The responses to the above SEs are being addressed through the ongoing NRC audit process (Reference 7).

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 18 of 22 7 Potential Safety Evaluation Impacts Section 6.5 addresses the additional Safety Evaluation (SE) Review items identified and evaluated during the MPS NRC Onsite Audit.Additionally, DNC is participating in the ongoing industry effort to develop guidance for the Final Integrated Plan that will support NRC preparation of the Safety Evaluation documenting MPS2 compliance with Order EA-12-049.

The format of the Final Integrated Plan is consistent with the Safety Evaluation Template provided with the July 1, 2014 Jack Davis memorandum (ML14161A643)(Reference 21).8 Supplemental Information This supplemental information provides details of the changes identified in the status updates above and addresses the following topics: a) a revision to Milestone Task'Develop Modifications', b) a revision to Milestone Task 'Implement Training', c) 'Issue FSGs and Associated Procedure Revisions', d) a revision to Milestone Task 'Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures', and e) a revision to Open Item No. 5.a) MPS2, Milestone Task 'Develop Modifications':

The revision to the scheduled target completion date is needed to obtain final design change approval of the MPS2 modifications to the ADV outlet piping and the Turbine Driven AFW pump exhaust supports.b) MPS2, Milestone Task 'Implement Training':

The revision to the scheduled target completion date reflects the current MPS2 scheduled training cycles necessary to complete training on the final approved FSGs.c) MPS2, Milestone Task 'Issue FSGs and Associated Procedure Revisions':

The revision to the scheduled milestone target completion date allows for completion of training on finalized MPS2 FSGs.d) MPS2, Milestone Task 'Validation Walk-throughs or Demonstrations of FLEX Strategies and Procedures':

The revision to the scheduled milestone target completion date allows for completion of the validation of the MPS2 FSGs based on the availability of required resources.

e) MPS2, Open Item 5: The Open Item completion date is revised to September 2015.The revision corresponds to the scheduled milestone target completion date and allows for completion of the MPS2 FSGs prior to the beginning of the currently scheduled MPS2 fall 2015 refueling outage.

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 19 of 22 9 References The following references support the updates to the Overall Integrated Plan described in this attachment and are available in ADAMS or have been provided to the staff for their review.1. DNC's Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2013 (Serial No. 12-161B).2. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12, 2012.3. DNC's Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated February 28, 2014 (Serial No. 12-161E).4. DNC's Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 23, 2013 (Serial No. 12-161D).5. DNC's Six Month Status Report in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049), dated August 28, 2014 (Serial No.14-393).6. NEI 12-06, "Diverse and Flexible Coping Strategies (FLEX) Implementation Guide," Revision 0, dated August 2012.7. NRC letter from Jack R. Davis, Director Mitigating Strategies Directorate to All Operating Reactor Licensees and Holders of Construction Permits, "Nuclear Regulatory Commission Audits of Licensee Responses to Mitigating Strategies Order EA-12-049," dated August 28, 2013 (ML13234A503).

8. Letter from Mr. Stephen Monarque (NRC) to Mr. Dave Heacock (Dominion) titled"Millstone Power Station, Units 1 and 2 -Report for the Onsite Audit Regarding Implementation of Mitigating Strategies and Reliable Spent Fuel Pool Instrumentation Related to Orders EA-12-049 and EA 12-051," dated November 17, 2014 (ML14275A017).

9. DNC's Supplement to Overall Integrated Plan in Response to March 21, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis Events (Order Number EA-12-049), dated April 30, 2013 (Serial No. 12-161C).10. Calculation 13-015, "MP2 & MP3 FLEX Strategy Hydraulic Calculations," Rev. 0.

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 20 of 22 11.Design Change MPG-13-00010, "BDB Storage Building/Millstone Power Station/Units 2&3." 12.ETE-CPR-12-0009, Rev. 3 "Beyond Design Basis -FLEX Strategy Overall Integrated Plan Basis Document." 13.Procedure CM-AA-BDB-102, Rev. 001, "Beyond Design Basis FLEX Equipment Unavailability Tracking." 14.PWROG letter, OG-13-197, Transmittal of PA-PSC-0965 Final CE-NSSS Specific ELAP Response (FLEX) Guidelines, May 17, 2013.15. Calculation 13-024, "Turbine Driven Auxiliary Feedwater (TDAFW) Pump Delivered Flow at Reduced Steam Generator Pressure," Rev. 0, April 22, 2013.16.Engineering Technical Evaluation ETE-MP-2013-1034, "MP2 Turbine Driven Aux Feedwater Pump Minimum Continuous Operating Speed," Rev. 0, dated March 12, 2013.17.Calculation 2013-ENG-04383E2, "Millstone Power Station Unit 2 Beyond Design Basis -FLEX Electrical 4160V, 480V and 120VAC System Loading Analysis," Rev.0.18. ETE-CPR-2013-0003, "Beyond Design Basis Communications Strategy/Plan," Rev.2.19. URS Geotechnical Investigation and Engineering Report, FLEX Storage Building Project, Millstone Power Station, Waterford, Connecticut, dated January 27, 2014.20. Millstone Power Station, Units 2 and 3 -Interim Staff Evaluation Relating to Overall Integrated Plan in Response to Order EA-12-049 (Mitigating Strategies), dated January 31, 2014.21.Memorandum from Jack R. Davis, JLD, Office of NRR, to Stewart N. Bailey, Sheena A, Whaley, and Jeremy S. Bowen, "Supplemental Staff Guidance for the Safety Evaluations for Order EA-12-049 on Mitigation Strategies for Beyond-Design-Basis External Events and Order EA-12-051 on Spent Fuel Pool Instrumentation," dated July 1, 2014 (ML14161A643).

Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 21 of 22 UNIT 2 cQ4AIjiwET Sq4JT t0ICM..U KA.T EXCWNCZ4GU 2-CS-4. 1B Z-SW- IZA RSOCCWi P ItI LEG~END j CD~ 90 MMOIPICATION FIGURE 10 CONTAINMENT COOLING- SPRAY OPTION BDB FLEX MECHANICAL CONNECTION MILLSTONE UNIT 2 Serial No. 14-393B Docket No. 50-336 Order EA-12-049 Attachment 1 Page 22 of 22 UNIT 2 CONTA I1*0JT*Z-R8-Z8.

tO FO r 2-Sw- IZA LC 2-Sw-8. tB 2-SW-8. IC RBCCV P- 118 2-SW-3B LEGENOs -.K79 BOB MODIFICATION FIGURE 11 CONTAINMENT COOLING -VENTILATION OPTION BDB FLEX MECHANICAL CONNECTION MILLSTONE UNIT 2